Global Bribery and Corruption Review 2013

The global effort to combat bribery and corruption continued in 2013. Countries that have traditionally been at the forefront of anti-corruption compliance and enforcement, such as the US and Germany, have continued their efforts to root out bribery across the globe. These traditional anti-corruption powerhouses are not alone anymore. Last year saw new legislation passed in countries such as Brazil and increased enforcement efforts across the globe.

In the US, reaffirming the government’s war against global corruption, acting assistant attorney-general (AAG) Mythili Raman in 2013 declared: ‘Fighting global corruption is, and always will be, a core priority of the Department of Justice.’ Since 2005, the US Department of Justice has secured close to three dozen corporate guilty pleas in Foreign Corrupt Practices Act (FCPA) cases and entered into more than 40 corporate resolutions, including nine of the top 10 largest monetary settlements, resulting in approximately $2.5bn (£1.5bn) in fines. In 2013, US authorities issued an ominous warning for companies: ‘Now is the time to enhance, not diminish, [y]our anti-corruption efforts.’ In the first section of this review, Hogan Lovells surveys FCPA enforcement actions in 2013 to help you understand current trends in order to avoid or minimise their risk under the statute. The firm also updates you, in section two, on two recent cases that have an important impact on foreign nationals and their susceptibility to US jurisdiction…

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